ACCELERATOR PEDAL INTERFERENCE

IN A JUNE 25, 2008, LETTER RESPONDING TO AN INFORMATION REQUEST FROM ODI, TOYOTA REPORTED AN APRIL 2003 UNWANTED ACCELERATION INCIDENT THAT OCCURRED DURING PRODUCTION DYNAMOMETER TESTING. ACCORDING TO THE LETTER THE INCIDENT WAS CAUSED BY A MISSING RETAINING CLIP THAT ALLOWED THE CENTER CONSOLE TRIM PANEL TO INTERFERE WITH (TRAP) THE ACCELERATOR PEDAL AFTER IT HAD BEEN DEPRESSED. IN THE AFTERMATH, TOYOTA REVIEWED THEIR MANUFACTURING PROCESSES AND OTHER DATA AND CONCLUDED THIS WAS AN ISOLATED INCIDENT. AS A SECONDARY MEASURE IN JUNE 2003, TOYOTA CHANGED THE DESIGN OF THE TRIM PANEL TO ELIMINATE THE POTENTIAL FOR PEDAL INTERFERENCE IN THE EVENT THE RETAINING CLIP IS NOT PRESENT. DURING A JULY 2008 MEETING WITH ODI, TOYOTA DEMONSTRATED HOW AN UNRESTRAINED EARLY DESIGN LEVEL TRIM PANEL INTERACTS WITH THE ACCELERATOR AFTER PEDAL DEPRESSION. TOYOTA ALSO ADVISED THAT THEY WERE CONDUCTING A FIELD SURVEY TO EXAMINE PANEL RETENTION AND THAT PRELIMINARILY ONE VEHICLE HAD BEEN IDENTIFIED WITH A CONCERN. NHTSA'S VEHICLE RESEARCH AND TEST CENTER IS ALSO CONDUCTING A SURVEY OF SUBJECT VEHICLES; PRELIMINARILY TWO RESPONSES ALLEGE A CONCERN. BEFORE OPENING PE08-025, ODI STAFF ALSO FOUND A SUBJECT VEHICLE WITH A MISSING RETAINING CLIP DURING A FIELD EVALUATION. NOTE THAT ODI IS NO LONGER COUNTING THE SINGLE COMPLAINT THAT WAS IN THE OPENING RESUME FOR PE08-025 AS IT WAS DETERMINED THAT THE VEHICLE INVOLVED WAS NOT EQUIPPED WITH THE SUBJECT TRIM PANEL. PE08-025 HAS BEEN UPGRADED TO AN ENGINEERING ANALYSIS (EA08-014) TO GATHER ADDITIONAL INFORMATION ABOUT HOW MANY SUBJECT VEHICLES MAY CURRENTLY HAVE ISSUES WITH THE RETAINING CLIP AND ASSESS THE FUTURE RISK OF PEDAL INTERFERENCE INCIDENTS DUE TO MISSING CLIPS.